February 1 was the date by which OSHA required your annual workplace injury records to be updated and posted. You are required to keep these records for at least five years. You must post the OSHA 301A Summary Form in a conspicuous location from February 1 through April 30. NJ Municipalities are not exempt from these requirements. The following information is provided to assist you in compliance.

The OSHA required recordkeeping forms are described below.

• The OSHA Form 300 (formerly the OSHA Form 200). This form is used to classify work-related injuries and to note the extent and severity of each case. The 300 Log can be maintained on a computer or at another location as long as you can produce a copy at the workplace whenever it is needed. You have seven calendar days to fill in the form once you learn of a case. You are required to keep these forms for five years.
• The OSHA Form 300A is the summary form that employers post from February 1 through April 30 each year listing the accident history of the previous year. Top management needs to be aware of the injury and illness experience and verify that records are accurate. For this reason the highest-ranking municipal official working at that site must sign and certify the summary.
• The OSHA Form 301 (formerly, the OSHA 101) includes detailed data about how the injury or illness occurred. The “First Report of Injury”, required by the State of New Jersey Division of Workers’ Compensation, is an acceptable substitute form.

What injuries do we record?

Even though a first aid injury may be compensable, these are not OSHA recordable. Work-related injuries beyond first aid are generally recordable.

An injury or illness is recordable, if it results in any of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness.

An injury is also recordable if it involves a significant injury or illness diagnosed by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.

Only new cases are reported. That means that if an employee aggravates a pre-existing injury, it is not reported as a new injury, but additional lost days may be added to the prior injury.

What do we do about employee privacy?

Employers are required to protect employee’s privacy by withholding an individual’s name on Form 300 for certain types of sensitive injuries/illnesses (e.g., sexual assault, HIV infections, mental illnesses, etc.).

Employee representatives are given access only to the portion of Form 301 that contains information about the injury or illness, while personal information about the employee and his or her health care provider is withheld. Employers are required to remove employees’ names before providing injury and illness data to persons who do not have access rights under the rule.